D195 MEL LOA for Part 91 Operators:
FAA AUTHORIZATION READINESS · Part 91
If you operate a single aircraft under Part 91, there's a good chance you've wrestled with MEL questions — what you're required to have, what you're allowed to defer, and how to stay legal when something breaks before a trip. The D195 LOA sits at the center of that picture.
REGULATORY FOUNDATION
What is a MEL and why does it matter?
Without an MEL Authorization, you're relying on the § 91.213(d) "Captain's determination" path, which is limited in scope and offers no deferral framework. An approved MEL, paired with your LOA, constitutes a Supplemental Type Certificate for the aircraft — it's a legal document with real operational weight.
UNDERSTANDING THE DOCUMENTS
MMEL vs. MEL — They're Not the Same Thing
The Master Minimum Equipment List is the FAA-approved, aircraft make/model/series-specific baseline document produced in coordination with the manufacturer during type certification. It defines which equipment items may be inoperative under certain conditions while maintaining airworthiness.
Think of it as the ceiling. Your operator MEL can be equal to or more restrictive than the MMEL — but never less restrictive.
A customized operator MEL is tailored to your specific aircraft's installed equipment, your operation, and your procedures. It incorporates required (M) and (O) procedures, definitions, a preamble, and other elements specified in AC 91-67. The MMEL is the foundation; your MEL is the finished structure built on top of it.
AUTHORIZATION TYPES
What Is a D195 LOA and Who Needs One?
The FAA provides two LOA types for Part 91 MEL authorization under § 91.213(a): D095 and D195.
D095 LOA: The MMEL itself — combined with a separate procedures document — functions as the approved MEL. It's a lighter lift administratively, but carries a meaningful limitation: a D095 LOA is not sufficient for international operations.
D195 LOA: You hold a fully developed, FAA-approved operator MEL — one document containing your preamble, definitions, all required M and O procedures, and equipment list, approved specifically for your aircraft.
If you're flying a U.S.-registered aircraft internationally, or have complex equipment configurations and operational flexibility requirements, the D195 LOA is the authorization you should hold.
THE PROCESS
How Do You Get One?
The process runs through the FAA Flight Standards District Office (FSDO) with jurisdiction over your principal base of operations. At a high level:
Develop an operator MEL based on the current MMEL revision for your aircraft make/model/series, ensuring it meets the content requirements described in AC 91-67.
Submit an attestation letter to your responsible FSDO confirming the MEL conforms to AC 91-67, identifying the MMEL revision it's based on, and including required operator and aircraft information.
FAA reviews and, upon approval, issues the D195 LOA.
Ongoing obligation: When the FAA publishes a new MMEL revision, you have 90 days to submit an updated MEL to your FSDO reflecting those changes.
The FAA's Part 91 LOA Application Guide provides the current attestation letter template and documentation checklist. Contact your FSDO before submitting — they expect it, and skipping that step can delay the process.
BOTTOM LINE
Key Takeaway
If you're operating under Part 91 without an approved MEL, you're limiting your operational flexibility and potentially your legal options when equipment goes inoperative. A D195 LOA gives you a compliant, aircraft-specific framework to manage those situations professionally — and it's the right foundation for any operator conducting or planning international flights.
Ready to Get Your D195 LOA in Place?
The documentation requirements, FSDO coordination, and MEL development steps take time and attention to detail. Allstate Aviation Solutions works directly with Part 91 operators to develop compliant MELs and navigate the D195 LOA process from start to finish — so you're not building it from scratch or figuring out the FAA's expectations on your own.
